In the Leser v. Garnett case of 1921, two Maryland residents sued to prevent women from voting, arguing that the state constitution only allowed men to vote and therefore the recently ratified 19th Amendment was invalid. They also claimed that several states which had ratified the amendment did not have authority to do so because their constitutions restricted suffrage rights or because they were part of a federal system where such changes should be uniform across all states. The Supreme Court unanimously rejected these arguments, upholding the validity of the 19th Amendment granting women's suffrage nationwide in America. This decision affirmed that once an amendment is officially included in U.S Constitution it becomes part of fundamental law and supersedes any conflicting provisions in individual state constitutions.

In the dissenting opinion for Leser et al. v. Garnett et al., Justice James Clark McReynolds argued that the Nineteenth Amendment, which granted women the right to vote, had been improperly ratified and was therefore invalid. He contended that several states who ratified it did not have legal authority to do so due to their own state constitutions prohibiting women from voting; thus, they could not consent on behalf of their female citizens. Furthermore, he believed that changes as significant as those proposed by this amendment should be made through legislative action rather than constitutional amendments in order to maintain a balance between federal and state powers. This view held an originalist perspective of constitution interpretation where any change must strictly adhere with procedures outlined within it.